Universities Superannuation Scheme 2014 Actuarial Valuation

Transcription

1 Universities Superannuation Scheme 2014 Actuarial Valuation A consultation on the proposed assumptions for the scheme s technical provisions and recovery plan October 2014

2 Contents Introduction 3 Background 4 A guide to this document 6 The underlying assumptions of the draft technical provisions 7 The discount rate 10 Reducing risk within the scheme 11 Contingent employer contributions 12 The draft recovery plan technical provisions and recovery plan: the draft results 14 The effect of changes to future benefits 15 Stability of contributions 16 Comparisons with the net asset value of the participating employers 16 Post-valuation experience 16 Next Steps 17 High level timeline 18 Appendix A: The guiding principles adopted by the trustee 19 Scheme funding and the trustee s technical tests 20 Appendix B: 2014 Draft Statement of Funding Principles 22 Notes to appendix B: Method and assumptions used in calculating the technical provisions 25 Appendix C: The underlying assumptions and sensitivity data 31 Appendix D: Glossary 38 Page 2 of 39

3 Introduction The trustee of Universities Superannuation Scheme is carrying out the actuarial valuation of the scheme s assets and liabilities as at 31 March This actuarial valuation is a legal requirement and must be completed every three years. The valuation is conducted by the trustee with the support of the scheme actuary, an appointed specialist who reports to the board, as required by law and under the scheme rules. The trustee, as explained in previous correspondence, anticipates a substantial deficit will be recorded when this formal valuation is complete and believes action must be taken now to ensure the level of risk inherent in the scheme remains proportionate to the support available from the participating employers. The trustee has been preparing for this valuation for some time, and over the past 12 months has been in dialogue with the scheme s participating employers both at an individual institution level and through Universities UK as the employers formal representative within the scheme for these purposes. This paper continues the trustee s engagement with the scheme s participating employers on funding matters but is also the first of a series of statutory consultations which the trustee must complete as part of the actuarial valuation processes. You will therefore find set out in this paper the principal underlying assumptions and data which the trustee intends to use to determine the value of the scheme s liabilities, and a draft of the updated Statement of Funding Principles. This consultation paper contains figures based on the member data as at 31 March 2014 which participating employers provided over the summer. It also confirms the assumptions the trustee intends to use for longevity and inflation, estimates of which were previously provided in the December 2013 Engagement Paper. Indeed, much of the information contained within this paper has been presented to the scheme s participating employers before, notably in the briefing papers issued to Universities UK in December and July. This consultation is to seek your feedback on the underlying assumptions which will be used to complete the formal valuation and more broadly the trustee s approach as set out in the Statement of Funding Principles. The trustee would welcome comments from Universities UK and through it from individual participating employers, on this paper by the end of November 2014 to enable the trustee board to consider responses in early December. Page 3 of 39

4 Background The primary duty of the scheme s trustee is to ensure that there are sufficient funds available to pay the pensions promised, as they fall due. The trustee fulfils this role alongside the scheme s stakeholders, formally represented by Universities UK and the University and College Union. In its preparations for this valuation the trustee has completed a substantial review of the three pillars of scheme funding upon which the security of the pensions promised depends; those are the support available to the scheme from the participating employers (known as the employer covenant), the investment strategy and the funding strategy. On employer covenant the trustee commissioned Ernst & Young (EY) to conduct a detailed examination of the financial health of a materially representative sample of the employers that stand behind the scheme. From this work the trustee was able to draw a number of conclusions which were shared with the scheme's participating employers through Universities UK in the Engagement Paper. The trustee s conclusions were: the covenant assessment confirmed the trustee s long-held belief that the covenant is robust; there is good visibility regarding the robustness of the covenant over a 20 year time horizon; beyond which visibility is reduced although the expectation is that the covenant will remain robust the majority of employers would be able to pay contributions of up to 25% of salaries albeit changes to operating models would likely be required and there could be some threat to the mutuality of the scheme. This is important as the amount of support available to the scheme from the employers dictates how much risk the trustee can reasonably take in delivering the benefits. Risk is inherent in the funding of the scheme, in particular in the investment of the scheme s assets and has an impact on the contribution requirements associated with providing a particular level of benefits. In broad terms the trustee believes the amount of risk taken should be proportionate to the amount of support available to the scheme from the employers, and specifically that there should be no increase in the reliance placed on the covenant over time. Indeed, it is the trustee s view that, with the right economic conditions, and following appropriate dialogue, opportunities should be taken to reduce the amount of risk within the scheme and therefore the reliance on the covenant. The trustee believes this is the right approach for the scheme as it will ensure that the contributions required from participating employers (and active members under the cost sharing arrangements) do not over time become too burdensome. After careful analysis of the information and consideration of advice provided by its advisers, and taking into account the views received from the scheme s stakeholders, the trustee developed three guiding principles for scheme funding, which are supported by a series of specific, technical tests. These principles and tests were shared with Universities UK in the July 2014 paper An Integrated Approach to Scheme Funding which was shared with the participating employers alongside a Universities UK consultation on the scheme's future funding and benefits. A copy of the principles and tests is available at appendix A. Page 4 of 39

5 The feedback the trustee has received from Universities UK has indicated that the participating employers broadly support the application of the principles and welcomed the trustee's transparency around this framework. However, some employers voiced concerns about how stringently the principles and tests will be applied. The scheme's stakeholders can be reassured that the trustee s intention is to use these tools as a reference and a guide to determine the nature and timing of any responses that might be required, rather than to produce prescriptive, binary decisions. The principles and tests will be used to analyse scheme risk over time and to highlight potential issues which can then be investigated further and discussed with employer and stakeholder representatives as appropriate. In preparing for this valuation the trustee has applied the principles and tests to the current funding arrangements. This analysis has indicated that the current arrangements require some revision and necessitate an updated recovery plan. Specific changes to pensions offered in the future are a matter for the scheme s stakeholders and the detail provided in this paper is based on the scheme arrangements (e.g. the benefits, member contributions, and cost-sharing arrangements) as currently specified in the scheme rules. The trustee has, both in this document and in the earlier Engagement Paper, indicated the quantum of change required to maintain the current level of risk within the scheme over a 20 year period, whilst recognising the contribution parameters advised by the participating employers. This information is intended to support the scheme s stakeholders in their ongoing discussions around the shape of future benefit and contribution structures. The trustee continues to support these ongoing discussions, providing information and modelling to enable the stakeholders, and through them the institutions and members, to understand the impact of proposed changes. It is not necessary to conclude those discussions before carrying out this consultation on the technical provisions, recovery plan and Statement of Funding Principles. The underlying assumptions presented in this paper remain broadly the same for most arrangements, and where there is an impact from potential changes to future benefit structures these have been explained below. Page 5 of 39

6 A guide to this document This consultation paper sets out the assumptions which the trustee, together with the appointed actuary, must make in order to calculate the scheme s liabilities that is the amount needed to pay the pension rights already accrued, both for pensions already in payment and those which will become payable in the future. These calculations are based on full member data assembled by the trustee, which (for active members) is supported by payroll and other data collected from the employers. The trustee takes a scheme-specific measure of the liabilities, known as the technical provisions, which includes a prudent allowance for future investment returns, and compares it with the assets currently held by the scheme in order to derive the contribution requirements. This consultation paper, and its appendices, include detailed information about the proposed assumptions to be used to calculate the funding level on a technical provisions basis. This calculation has, as anticipated, shown the scheme continues to have a substantial deficit and this paper therefore also includes a draft recovery plan for consultation. In appendix C the draft Statement of Funding Principles (SFP) is provided and this includes an explanation of the reasoning behind the assumptions, in line with Pension Regulator s best practice, as well as more detailed information about the assumptions themselves. This paper is the first in a series of formal consultations which the trustee will carry out as part of the valuation processes. Subsequent consultations will be completed on the Schedule of Contributions, Statement of Investment Principles and, depending on the nature of any proposal coming out of the current discussions 1, an employer consultation with affected employees on changes to future benefits, for which the trustee will provide guidance and practical support. In addition to the statutory requirements the trustee has also provided further information about its integrated approach to scheme funding, the development and application of the principles and tests which were presented to the participating employers in July and some additional information about the valuation timeline. There is also a glossary of technical terms towards the back of the document. It is hoped that this information proves useful in preparing any response to the consultation. The trustee looks forward to receiving your comments. 1 Notably whether those changes are identified in statutory regulations as requiring a formal consultation with affected employees Page 6 of 39

7 The underlying assumptions of the draft technical provisions The technical provisions are a prudent estimate of the assets needed to pay the pensions promised. The technical provisions calculation requires the trustee to make a number of demographic and financial assumptions. These assumptions are reviewed at least every three years as part of the formal valuation process to ensure they remain relevant to the scheme s experience and are in-keeping with wider trends. The 2014 technical provisions are developed by reference to the assumptions used for the previous formal valuation in 2011, details of which are available in the Statement of Funding Principles (SFP) dated 15 June 2012 which is available on the USS website The key adjustments to the assumptions proposed for the 2014 Valuation (compared to the 2011 SFP) are as follows: A strengthening of the mortality assumptions to include (i) an update from the 2009 Continuous Mortality Investigation (CMI) table to the 2012 CMI table alongside the maintenance of the same scheme-specific adjustments to those tables as used in 2011, and (ii) allowance for future improvements in mortality to incorporate a longer-term improvement trend of 1.5% per annum compared to the 1.25% per annum used in A reduction in the inflation risk premium adjustment applied to the market-implied RPI inflation rate from 0.3% per annum to 0.2% per annum. A gradual reduction of investment risk over a 20 year period in order that the scheme s reliance on the employer covenant does not increase. This will be reflected over that same period in (i) a change to the discount rate, and (ii) a change in the inflation risk premium. Page 7 of 39

8 The table below provides a commentary on the principal assumptions used for the 2011 valuation and, where a change is proposed a description of the nature of the change and the financial impact it has on the scheme s liabilities. Change in liabilities Assumption Inflation risk premium RPI / CPI gap Salary increase assumption Rationale The proposed reduction from 0.3% per annum to 0.2% per annum reflects an allowance for the increased level of inflation hedging which is either already in place or is anticipated. The financial effect of this is to increase the technical provisions by 0.9 billion. Retail Price Index (RPI) and the Consumer Price Index (CPI) are two different measures of inflation. Objective market information is available in relation to the long-term RPI whereas the scheme s benefits typically increase in line with CPI which is generally expected to be lower than RPI. An assumption therefore needs to be made for the long-term RPI / CPI gap. For the 2011 valuation the RPI / CPI gap was assumed to be 0.8% per annum. There has been nothing to suggest the assumption adopted for the 2011 valuation should be amended and therefore no change is proposed. The assumption used in the 2011 valuation was based on a general pay growth assumption of RPI + 1% per annum plus an additional allowance for increases above the general pay growth scale. The salary increase assumption needs to be specific to the sector and the membership of the scheme rather than what may be considered appropriate to the economy as a whole. Historic experience is taken into account but ultimately a forward looking assumption needs to be made which is considered appropriate for the very long-term horizon and expected career progression covering all the final salary active membership of the scheme. These long-term, scheme-specific, principles are applied consistently, for example, to the choice of the discount rate as well as the salary increase assumption. Over such long-term time horizons and career progression an individual s salary increase will be a complex aggregation of what could be modelled as general pay increases and a variety of other less general elements, including promotional increases, covering an individual s career path through potentially a number of different institutions. The scheme s salary increase assumption, which comprises a general pay increase assumption with an age-related salary scale, therefore represents a simplified representation and it is the combined effect of the two assumptions which is important for calculation of the liabilities. Page 8 of 39

9 It should also be borne in mind that the USS pensionable salary (the salary used to calculate the amount of scheme benefits) is subject to a minimum of a dynamised pensionable salary calculation which takes into account pensionable salaries over the last 10 years increased in line with RPI. The analysis of scheme experience over many years has been shared with Universities UK and University and College Union representatives to support the formation of a continuing long-term assumption for future increases. These data demonstrate that over the 20 year period to 2014, the general pay increase was equivalent to RPI. If we exclude the last three years, the general pay growth experience was RPI + 0.7% per annum. Annual analysis over the last few years indicates additional pay increases over and above the general pay growth assumption have been broadly in line with the age-related salary scale assumption used for the 2011 technical provisions basis. Having considered both the past and future outlook of salary increase data for USS members, and having engaged in substantial dialogue with stakeholder representatives, the trustee is minded to retain the 2011 salary increase assumption of RPI +1% per annum plus the age-related salary scale for this valuation. It should be noted that a lower age-related salary scale assumption is currently used for the calculation of the future service cost (compared to the salary scale used for past-service increases), which reflects the expectation that in the longer-term such increases would be in line with a lower scale excluding some historic factors which it is not anticipated will be repeated. Further details on this assumption are available in the Statement of Funding Principles. The trustee is minded to maintain this approach for the 2014 valuation. Life expectancy (base table) The 2011 assumption was based on a detailed analysis of the scheme membership; experience over the inter-valuation period is broadly consistent with that assumption. The trustee will therefore update the base table used from the 2009 version to the 2012 version alongside maintenance of the same scheme-specific adjustments to these standard tables as were used in This change leads to an increase in the value of the liabilities of less than 0.25% or 0.1 billion. Page 9 of 39

10 Life expectancy (future improvement rate) The trustee proposes to strengthen the allowance for future improvements in mortality to reflect emerging trends. The long-term improvement assumption now incorporates a more recent version of the standard mortality table and has also been strengthened to incorporate a higher longer-term improvement trend of 1.5% per annum compared to the 2011 assumption of 1.25% per annum. In this context, it can be noted that the Pensions Regulator s latest survey shows that around 65% of schemes use a long-term improvement rate of 1.5% per annum or more. The financial effect of this is to increase the technical provisions by 0.9 billion. Demographic assumptions (covering early retirement, withdrawals from service, ill-heath retirement, and likelihood of beneficiary pension entitlements) Inter-valuation experience has been analysed where available and compared to the assumptions made for the 2011 valuation. The analysis in relation to withdrawal and ill-health early retirement rates suggests that, to varying degrees, the current assumptions may be conservative compared to recent experience. However taking due account of the level of reliance which can be placed on data over any particular short period, and the limited materiality of any potential changes to the overall valuation outcome, the trustee is satisfied that the 2011 assumptions remain reasonable and no change is proposed. Further details of the individual actuarial assumptions are included in the proposed draft Statement of Funding Principles which is attached at appendix C. The discount rate The discount rate is effectively an allowance for future investment returns which is used in the calculation of the technical provisions. It enables the trustee to place a present day value on the assets needed to pay the pensions already promised. The initial discount rate is calculated with reference to the specific assets held by the scheme. Different asset classes provide different expected rates of return. A combined overall anticipated rate of return is first determined and then adjusted to provide a prudent discount rate with which to value the scheme s liabilities. This approach allows for the actual range of investments made by USS to be reflected in the technical provisions. In deriving its long-term return expectations, the trustee takes into account the views of USS s internal investment team and its independent investment advisers on the prospects for all major asset classes, including equities and inflation-linked gilts. These assessments are made on both an equilibrium basis (assuming asset markets are fairly valued at present) and on a valuation-adjusted basis (accounting for an assessment of market over or under valuation). Page 10 of 39

11 The expected returns on each asset class, and the discount rate, used by the trustee are expressed by reference to the gilt yield which allows the scheme s stakeholders to make comparisons, for example, over time, with other asset classes, and with comparator schemes. The gilt yield is calculated as the average equivalent rate of the gilt yield curve 2 as at 31 March 2014 weighted by the profile of the scheme s projected cash flows. The trustee s view of the long-term best estimate return on its current investments that is the expected rate of return which might be achieved 50% of the time as at 31 March 2014 is equivalent to gilts +2.75% per annum. As mentioned, in determining the discount rate the trustee must also make an allowance for the prospect that investment performance falls below expected levels. For the 2011 valuation the trustee adopted a discount rate equal to gilts +1.7% per annum. For the 2014 valuation the trustee has concluded that it would wish to continue the approach adopted previously in order to calculate the initial discount rate at a gilts +1.7% per annum which therefore contains a margin of prudence of just over 1% per annum compared to the best estimate return; this approach is also in line with the continuing advice of the scheme actuary. In the longer-term the discount rate is driven by the trustee s desire to manage the scheme s reliance on the covenant of the participating institutions (as defined below) which impacts the amount of investment risk the trustee is comfortable with, and hence the discount rate. Under the risk parameters agreed by the trustee the discount rate in 20 years is determined in order to keep the difference between the technical provisions and the value of the liabilities measured on a self-sufficiency basis within a desired range. It is therefore proposed that the allowance for outperformance, over gilts, of 1.7% per annum is reduced gradually over a 20 year period. The actual amount of reduction in investment risk the trustee will seek and therefore the level of outperformance the trustee will be aiming for at the end of that 20 year period will to some extent depend upon the level of future benefits that are to be provided. The subsequent section of this paper includes further information on the strategy to manage risk as the scheme evolves, and the impact that it has on the assumptions supporting the technical provisions for the 2014 valuation. Reducing risk within the scheme In broad terms the trustee believes that the amount of risk taken should be proportionate to the amount of support available to the scheme from its participating employers, and specifically that there should be no increase in the reliance placed on the covenant over time. The reliance on the covenant is measured by comparing the value of the liabilities on a technical provisions basis with a calculation of the liabilities on a self-sufficiency basis 3 which assumes a low risk investment strategy. Projections indicate that if the trustee maintained the current investment strategy and hence the same discount rate in 20 years time, there would be a significant increase over that period in the reliance on the covenant. The trustee has therefore proposed a targeted reduction in investment risk and therefore the discount rate in order to maintain the reliance on the covenant within specific parameters. Adopting this targeted approach the trustee would, given the right economic conditions, seek opportunities to reduce the amount of investment risk over time. 2 This represents the yields on gilts over different time periods 3 See glossary for complete definition of the self-sufficiency basis Page 11 of 39

12 Contingent employer contributions In the absence of contingent assets, which in many single employer arrangements have been used to provide tangible support for pension funds, the trustee has sought to identify contingent employer contributions. This is the essence of the first principle and relevant supporting test set out by the trustee and has been defined as the difference between the level of contributions the participating employers have indicated is the maximum desirable - which is 18% of salaries - and the level identified by EY, the trustee s covenant assessors, as the rate which the majority of employers would be able to pay - which is 25% of salaries, albeit not without, in some cases, substantial changes to operating models and some threat to the mutuality of the scheme. In order to estimate the reliance on contingent employer contributions, the value of the scheme s liabilities on both a technical provisions and self-sufficiency basis are projected over a 20 year period. The median outcome is then taken and used to compare the two bases. Within that calculation is an assumption for the level of inflation over the next 20 years and a projected discount rate at the end of that period, the latter (critically) being set to fulfill the trustee s requirement that there is no increase in the reliance on the covenant in real CPI terms. Based on the above approach, if the current benefit structure were to be maintained going forwards, the trustee would seek to gradually reduce the discount rate (and correspondingly the inflation risk premium) to a level which equates to gilts +1.1% per annum, over a 20 year period. For the 2014 formal valuation, based on the current benefit structure, this means the trustee will adopt: A discount rate of gilts +1.7% per annum in year one, reducing linearly (for the purposes of the valuation calculations) to gilts +1.1% per annum in year 20 and beyond An inflation risk premium of 0.2% in year one reducing linearly (for the purposes of the valuation calculations) to 0.1% per annum in year 20 and beyond In reality the trustee would seek appropriate opportunities to make investments in risk-reducing assets. The route the trustee would take in order to reduce risk would be more variable but using a targeted linear route enables sensible calculations to be made. In developing the approach detailed in this paper, the trustee considered whether the different duration of liabilities for past service benefits and future service accrual would justify the use of a different value for, say, the gilt yield and inflation assumptions. Following further analysis it was felt that any difference in these assumptions would be marginal and therefore the trustee proposes to use the same assumptions for the calculation of the cost of future service benefit accrual as used for the technical provisions, albeit, as noted earlier, a lower age-related salary scale for the future service calculations compared to the technical provisions basis. It is worth noting that the trustee s plan to gradually reduce risk in the scheme does not result in a derisked investment approach. The targeted position still means a substantial amount of the scheme s investments would be in return-seeking assets in 20 years time. Taking this approach means that even in 2034, having reached the reduced risk position the trustee has set out, the fund would still contain a significant amount of investment risk which would be consistent with a scheme backed by robust employers such as those which sponsor USS. Page 12 of 39

13 The trustee s approach means that the discount rate in 20 years time (reflecting the reduced risk position) depends on the level of future benefit accrual, as that has a significant impact on the quantum of liabilities built up over time and therefore the calculation of the reliance on covenant. This is explored further in the section below on the impact of potential changes to benefit arrangements. Further details of the trustee s approach to the de-risking strategy were set out in the July 2014 paper An Integrated Approach to Scheme Funding and the full text of the trustee s principles and tests is available in appendix A. The draft recovery plan Based on the trustee s proposed assumptions, there is a shortfall between the value of the scheme s assets and the value of the liabilities, as calculated on a technical provisions basis. Accordingly, the trustee must set out a plan for returning to a fully funded position. This is known as a recovery plan. Following the 2011 valuation, which reported a 2.9 billion deficit, the trustee in consultation with the scheme s stakeholders implemented a 10 year deficit recovery plan. There were two components to this recovery plan; firstly the payment of contributions in excess of the value of accruing benefits, and secondly the assumption that the scheme s investments would deliver a return approximately 0.5% per annum greater than the assumption made for the discount rate in the 2011 formal valuation. The first component involved employers making payments in the first six years of the recovery plan period at 16% of salaries, which was broadly 3.4% above the cost of accrual determined at the 2011 valuation. For the remaining four years the employers were due to make payments at 2% of salaries in excess of the (then) estimated future cost of accruals. Since the deficit recovery plan was put in place the participating employers have made deficit contributions of 0.7 billion. In addition the in-house investment team has achieved an additional 2.1 billion investment outperformance, over and about the 0.6 billion anticipated outperformance which had been built into the recovery plan. This would have been enough to return the scheme to an almost fully funded position, if all other elements had remained equal. However, the value of the liabilities has increased substantially since 2011 and this has created a materially larger deficit, with changes in investment outlook (in particular gilt yields) adding 7.6 billion to the scheme s liabilities. The trustee proposes that a broadly similar approach to that used in 2011 is adopted for the updated recovery plan to be decided upon following the 2014 formal valuation and the estimated cost of employer contributions to the deficit is set out in the section below. The additional assumed outperformance to be included in the updated recovery plan will be aligned to the reduction in risk and therefore the discount rate which the trustee proposes to implement gradually over the period of the recovery plan. It is therefore proposed that the additional assumed outperformance during the recovery period will be 50% of the difference between the technical provisions assumed discount rate and the best estimate return from the investment strategy. In year one this would provide an extra investment return of circa 0.5%. This would then gradually reduce in line with the reduction in investment risk and discount rate. The length of the recovery plan is a further decision point for the trustee, following consultation and taking into account the strength of the employer covenant, the size of the deficit and the level of risk inherent in the scheme. For the deficit identified at the 2011 formal valuation the duration of the recovery plan was 10 years. Based on the detailed work undertaken by the trustee s independent covenant advisers, EY, which in particular considered the potential period of visibility of the covenant, the trustee believes it would be reasonable to agree to a longer recovery period for the 2014 formal valuation. From EY s work the trustee Page 13 of 39

14 was able to conclude that there was good visibility over the covenant for a period of 20 years. The trustee has some concerns about extending a recovery plan to the full length of the covenant horizon; using the maximum time available now would leave little room to accommodate any future adverse experience. The trustee therefore proposes that a 15 year recovery period is adopted. Future benefit structures are a matter for the scheme s stakeholders. The trustee is aware that one proposal put forward assumes that a 20 year recovery plan is adopted and this has therefore been modelled and the results are set out in the sensitivity analysis in appendix C. However, this should not be read as the trustee s acceptance of this proposal technical provisions and recovery plan: the draft results Taking the updated assumptions as outlined above, including the trustee s plan to reduce risk within the scheme and applying those factors to the current benefit structure, the technical provisions for the 2014 valuation are: Assets Liabilities on a technical provisions basis Deficit Future service contribution rate Deficit contribution rate (15 year 4 recovery period) Total contribution rate Employee contribution rate 5 Final salary members CRB members Employer contribution rate 31 March bn 53.9bn 12.3bn 28.4% of payroll 9.8% of payroll 38.2% of payroll 12.7% of payroll 11.7% of payroll 25.7% of payroll The trustee recognises that, on this basis, the contribution requirements for the current benefit package fall above the 25% threshold, which EY identified was the maximum contribution rate that the majority of employers could pay, albeit in some cases not without significant change to operating models and substantial threat to the mutuality of the scheme. The trustee s priority is to ensure that there are funds available to pay the pensions already promised as they fall due and the backing of a robust and sustainable employer remains a key part of achieving that objective. Ensuring pension arrangements do not have an adverse impact on an employer s ability to achieve sustainable growth is also a key concern for the Pensions Regulator. The trustee s plan to reduce risk within the scheme would, over the long term, deliver increased contribution stability enabling some confidence that contributions would not become unaffordable and that the scheme s reliance on the participating employers would remain proportionate to the support available from them. 4 It is assumed that the 15 year period is measured from 31 March 2014 but that the current employer contribution rate of 16% is payable until 30 June Assuming that the current cost sharing principle is applied Page 14 of 39

15 The proposed cost of current benefit arrangements may prove prohibitive for members; the technical provisions show that, under the cost sharing arrangements, members would be required to pay 12.7% and 11.7% for the Final Salary (FS) and Career Revalued Benefits (CRB) sections respectively. Whilst changes to future benefit structures are a matter for the scheme s stakeholders, the trustee believes that the valuation of the current benefits package on a technical provisions basis demonstrates that these arrangements are unsustainable. In addition to breaching the maximum contribution rate identified by the covenant assessment, the current benefit arrangements, combined with the impact of reducing investment risk over a 20 year period, also puts the funding arrangements beyond the parameters the trustee has set out in the principles and tests. As previously explained, this alone would trigger a discussion with the scheme s stakeholders around scheme funding. As it is, these discussions began some time ago in preparation for the 2014 formal valuation and they are ongoing. The trustee continues to support the scheme s stakeholders in these discussions and in particular to provide guidance around whether proposed changes to future benefits would satisfy the trustee s principles and tests for scheme funding going forward. The subsequent section examines the effect of potential changes to future benefits on the scheme funding arrangements. This information is provided so that there is some transparency around the scale of change potentially required and should not be taken as the trustee advocating a particular approach. The effect of changes to future benefits The trustee s approach means that the targeted discount rate (the reduced risk position) depends on the level of future benefit accrual. Changes to future benefit structures could have a significant impact on the quantum of liabilities built up over time and therefore the amount of liability risk within the scheme. The trustee is concerned with managing risk across the whole scheme if the scheme s stakeholders choose to reduce scheme risk it enables the trustee to take more risk in its investment strategy as long as the overall reliance on the covenant remains in proportion with the employers ability to support the scheme. This means that the targeted discount rate in 20 years time depends to some extent on the level of future benefit accrual. Given the inherent sensitivity of projections over a 20 year period to the assumptions made, the trustee does not believe it is appropriate to apply an overly precise relationship between the level of benefit accrual and the targeted discount rate. It is therefore difficult to provide a precise indication of how a particular quantum of benefit change (either expressed as a percentage of pensionable salary or as a proportion of the overall benefit) may impact the discount rate as different types of benefit design may have a different impact over time. For example, the cost of a scheme design related to a capped pensionable salary would be expected to change over time when that cost is expressed as a percentage of full salary. In order to give a broad indication of the size of the potential change we can say that if the final salary link for past service was replaced with CPI, and future service benefit accrual was changed such that the cost of future defined benefits accruing fell by the order of approximately 8% of total payroll then the ultimate discount rate could rise from gilts +1.1% to gilts +1.25%. This would result in a lower employer contribution for the new benefit structure of the order of 16.9% compared with 25.7% for the current benefit structure (and lower member contributions). Page 15 of 39

16 Stability of contributions The essence of the trustee s second principle and supporting test is that there should be some confidence that employer contribution rates will fall within certain parameters. The contribution parameters have been determined after consultation with the scheme s participating employers, and focus on two specific employer contribution reference points of 18% of salaries (the amount the employers have indicated is the maximum desirable contribution) and 21% of salaries (the threshold identified by EY as an amount the majority of employers could pay albeit with some changes to operating models). The trustee believes it is important that the scheme s stakeholders are fully informed of the potential volatility in future contribution requirements by considering the range of possible outcomes in three years time i.e. at the next actuarial valuation. Once the underlying assumptions behind the technical provisions have been agreed by the trustee, taking into account any feedback from this consultation, further work will be done on future contribution volatility. In particular, as the scheme s stakeholders progress the current discussions around future benefit structures, this modelling can reflect any specific options being considered. The trustee will be pleased to work with stakeholders to share this information as it becomes available. This will help form a view on the likely sustainability of future benefit arrangements. Comparisons with the net asset value of the participating employers The final aspect of the trustee s updated funding approach is a comparison between the estimated net asset value of the participating employers compared to the deficit on an economic basis (for this purpose a discount rate equal to the yield on gilts is used) plus the amount of additional assets required to meet a 1 in 100, funding event. The trustee acknowledges that the net asset value of the scheme s participating employers is not precisely quantifiable; however, the trustee is keen to ensure that the scheme does not appear to threaten the solvency of the participating employers. Monitoring the ratio between the scheme s funding position on an economic basis with an allowance for an extreme shock and the net asset value of the participating employers enables the trustee to have a sense at a macro level of the size of the scheme relative to the participating employers ensuring the two continue to remain in proportion. To this end, the trustee would see the ratio exceeding 90% as a point at which there may need to be a further dialogue with the scheme s stakeholders. Post-valuation experience The formal valuation is being carried out as at 31 March 2014 and the trustee would not necessarily look to reflect changes in market conditions since then in the outcome of 2014 valuation, if such changes could reasonably be considered to be within the normal volatility which is inevitably associated with the funding position. However, if this post-valuation date experience were considered to be sufficiently material and sustained, i.e. representing a long term shift, then it may be appropriate to consider whether this should be reflected in some way in the outcome of the 2014 valuation. Since 31 March 2014 there has been a significant reduction in the funding level due to adverse financial experience. The UK equity market has fallen by around 7% between mid-september and mid-october and long-dated government gilt yields have also fallen significantly at the same time. At this stage, the trustee is cognisant that the changes have occurred over a relatively short period, that markets remain volatile and a long-term approach needs to be taken. The trustee therefore intends to continue to monitor closely how the position evolves. The trustee will in due course need to form a better understanding of the circumstances which have led to the recent experience, how sustained this is likely to be in terms of the Page 16 of 39

17 outlook for the long-term future and the consequences of various future scenarios and the potential implications for overall scheme risk and therefore the principles and tests. Ultimately whether or not it is necessary to reflect any part of the post-valuation experience in the contribution rates agreed as part of the 2014 valuation will require much fuller consideration and will depend upon further experience. Next Steps This paper begins the formal valuation processes; that is the consultation on the technical provisions, the recovery plan and the trustee s Statement of Funding Principles. The trustee welcomes feedback from Universities UK and through it individual institutions on any of the matters covered in this consultation. Responses by the 28 November will enable the trustee board to consider participating employers feedback in early December. It is hoped that this consultation and its appendices explain the rationale behind some of the judgements the trustee must make about the economic and demographic changes which impact the scheme over many decades. These challenges are certainly not unique to USS; all defined benefit pension schemes are making these adjustments. They are however complex and require constant monitoring to ensure the reliance the scheme places on the participating employers remains proportionate to the support available. The trustee has a duty to take account of the particular characteristics of this scheme, of its operating environment and of the prospects for the participating employers, in its judgement of the appropriate level of investment risk for the scheme the third principle, the comparison to the net asset value of the sector does this in very broad terms in a manner which is accessible. Continuing engagement with the scheme s stakeholders is important as the valuation progresses and the trustee envisages further consultation and engagement with both employers and members, and their representatives. The trustee wishes to be as transparent as possible about its approach to scheme funding and will continue to update its website ( as appropriate. Page 17 of 39

18 High level timeline The timeline below sets out some high level activities which will take place during this period, however, it should be noted that there shall continue to be engagement with the scheme s stakeholders outside of these more formal pieces. At present it is difficult to give precise dates as the discussions between the scheme s stakeholders must be able to progress appropriately. As an indication, formal valuations must be completed within 15 months of the valuation date which provides a deadline of 30 June Page 18 of 39

19 Appendix A: The guiding principles adopted by the trustee The guiding principles, adopted by the trustee in order to manage scheme funding, draw very clear lines between the support available from participating employers and scheme risk over the horizon of the covenant (and the trustee s view is that it has good visibility of the covenant over a period of 20 years). This is in keeping with the trustee s long-term view of the scheme and its approach to funding and investments. These principles will be reviewed and employers will be consulted on a continuing basis. The guiding principles for scheme funding adopted by the trustee can be summarised as follows: 1 Reliance of the scheme on the sector Over the period for which there is visibility of the covenant (estimated to be 20 years) there should be no increase in USS s reliance on the covenant of the sector and, where opportunities arise, the reliance on the covenant should be reduced if possible. The reliance on the sector will be measured as the additional contributions which would be required if the trustee moved to a relatively low risk approach to investment strategy and therefore could not rely on the same level of investment returns which are anticipated under the current investment strategy. 2 Stability of contributions There should be a high probability that the employer contribution rate will not exceed 18% of salaries over a three year period and there should be a very high probability that the employer contribution rate will not exceed 21% of salaries over the same period. In the longer term the stability of the contribution rate should be increased. 3 Investment risk and tail risk 6 The balance sheet of the scheme s participating employers should be able to cover the impact which a rare set of adverse circumstances (tail risk) may have on the funding position of the scheme. This includes being able to cover both the level of any existing deficit, plus an allowance for a potential increase in this deficit over a one year period if an exceptional economic event were to occur with resulting adverse impacts on investment returns. 6 The investment strategy being followed by the scheme means that, in extremis, there is a very large range of uncertainty in the potential change in the deficit which could take place over even relatively short periods, such as one year. These changes could take place through, say, a particularly adverse combination of changes to long-term interest rates and / or the level of the stock market. Within this range of uncertainty, there is a long tail of outcomes with a relatively low probability but a very high impact on the deficit. Tail risk is therefore a measure of the potential impact of these low probability outcomes it is often quantified as a single number called the Value at Risk or VaR associated with different levels of probability. It is a scheme-specific measure because it depends on the profile of the scheme s liabilities and the investment strategy being followed. Since the tail risk considers relatively unlikely events it is not used as part of the main set of parameters for setting the contribution requirements. However the tail risk cannot be ignored as it is an important element for the trustee in considering the ultimate security of benefits. In practice it needs to be looked at to ensure that the tail risks arising from the scheme s investment strategy are supportable given the potential for changes in contributions or additional mitigating actions. A similar concept is used by financial institutions, such as insurers, in measuring their resilience to market shocks. Page 19 of 39

20 Scheme funding and the trustee s technical tests The three guiding principles identified above are supported by a number of specific technical tests; this approach enables the trustee both to assess any scheme changes proposed by the employer and member representatives in relation to the current scheme funding challenges, and to manage the scheme going forward. The tests inform the trustee s decision making on the degree of risk which is acceptable within the scheme and specifically in delivering both the past and future benefits. These decisions are formed by both looking at the risks in the short term but also importantly how these are likely to build up over longer time horizons, particularly the 20 year period over which there is good visibility of the covenant. The calculations on a technical provisions basis involve placing a current value on commitments which will run for many decades into the future, and the USS trustee just like other trustees of defined benefit schemes must make sensible and prudent judgements regarding the rate of return that can be expected in the long term on future investments, along with other appropriate assumptions. The trustee will use these tests as a reference and guide to determine the nature and timing of any responses that might be required. Test 1: Benefit security and additional contribution cover The difference between the liabilities assessed on a self-sufficiency approach (for this purpose a discount rate of gilts +0.5% is used) and the actual technical provisions basis should generally not exceed what we refer to as the amount of contributions payable in extremis, which we will indicatively measure as the difference between (i) the maximum contribution of 18% of salaries stated by the employers as being desirable and (ii) the maximum identified as being affordable by employers (in the independent covenant review undertaken by EY on behalf of the trustee board) of 25% of salaries, over a long period such as 15 to 20 years. The rationale is that, at any given time, the trustee could be required to replace the investment returns assumed in the funding of current benefits with additional contributions from the participating employers, if such a response were needed due to scheme or economic circumstances. In considering the development over time of the relationship between the liabilities measured on a selfsufficiency basis and on the technical provisions basis, the position at the end of a 20 year horizon will be used. The size of the technical provisions at the end of 20 years will be determined so that the difference between it and the self-sufficiency value of liabilities remains broadly constant. This informs the trustee of the size of the technical provisions required, and from that the required investment strategy can be derived. It s the gap to the self-sufficiency funding level that is critical, and that is maintained (and not allowed to grow disproportionately) by keeping the technical provisions value at a sufficient level over time. Page 20 of 39